If there is one thing that can be guaranteed, it is that people will not behave as forecast.
This is a lesson you can learn from town planners, who will happily confirm to you that building more roads is likely to increase traffic rather than decrease it – a phenomenon known as induced traffic – because it encourages drivers to use the new road rather than leave their car at home.
The Financial Conduct Authority appears to have fallen for a similar trap with its rules around triage.
As part of the new rules, any guidance based on a consideration of a client's circumstances that "steers them one way or the other" is likely to be considered advice rather than guidance.
This was introduced after the FCA found a "lack of understanding" among advisers of the boundaries between guidance and advice and it now seems advisers have decided to act.
Advisers appear to have decided that if the FCA wants to set a higher bar for their triage services, then they will charge for it.
This does not appear to be in conflict with the regulator's rules and is an entirely reasonable conclusion to have reached: if the FCA is going to set high standards for triage, then advisers should not be expected to give it away for free.
Ultimately, it is a commercial decision and the more complicated and time-consuming a service is to provide, the more likely it is advisers will want to charge for it, for entirely legitimate reasons.
The problem here is that it will leave savers with fewer avenues to go down if they want to figure out what on earth they should do with their pension.
Already professional indemnity insurers are restricting the amount of defined benefit transfer work that advisers can undertake in a year.
And a triage service can be helpful for the adviser – to find out whether there is any business to be had – and the client, who may just need a couple of pointers here and there or may need full fat advice.
Instead, savers may find themselves in a traffic jam of options, struggling to find an exit.
damian.fantato@ft.com
